ITA 3838/DEL/2026 & Others SUMAN TECHNOMECH PVT.LTD. & OTHERS
Parties Involved
Facts Summary
The appeals were filed by different assessees against orders passed by the Commissioner of Income Tax (Appeals) under section 250 of the Income Tax Act, 1961. The assessees challenged the initiation of proceedings under section 153C of the Act, claiming that the proceedings were barred by limitation and based on defective satisfaction. The satisfaction notes did not specify that the documents pertained to the assessee and had a bearing on the determination of the total income. The assessees argued that the delay in recording satisfaction and the defective satisfaction notes rendered the proceedings invalid.…
Decision in favour of
Assessee
Legal Issues
- 1. Whether the initiation of proceedings under section 153C of the Act was barred by limitation?
- 2. Whether the satisfaction recorded by the Assessing Officer was defective?
Judgment Outcome
Decided in favour of Assessee.
Precedents Relied Upon
6 precedents cited in this judgement.
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